FDIC Federal Register Citations

From: morris hershman [mailto:mhershman@firststerling.com]
Sent: Wednesday, October 20, 2004 1:08 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

The proposed changes to the regulations regarding community reinvestment audits of institutions with assets in excess of $250 million will be quite detrimental to the low income housing tax credit program, which is a major stimulus to the economy of the United States, and of great social benefit to lower income households. Compliance with community reinvestment requirements is a material motivation for financial institutions to make investments in low income housing tax credit investments in areas that would otherwise have great difficulty in obtaining such investments, despite demonstrated need for such housing.

Morris P. Hershman
General Counsel
First Sterling Financial, Inc.
1155 Northern Boulevard, Suite 250
Manhasset, NY 11030